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Home My WebLink About09-2488IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff No. OQ' - Agss (21vi tTer? VS. LARRY R SHELLER Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, Esquire PA I.D. 942524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6609734 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC. Plaintiff vs. Civil Action No. LARRY R SHELLER Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 200 BARR HARBOR DR STE 400 W. CONSHOHOCKEN, PA 19428-0000. 2. Defendant is an adult individual residing at 1048 TRINDLE ROAD CARLISLE,PA 17013. 3. At the specific instance and request of Defendant, CARLISLE REGIONAL MEDICAL CENTER, provided certain medical services to Defendant. 4. This obligation was subsequently assigned to Plaintiff for value. 5. Defendant, LARRY R SHELLER, received and accepted the aforementioned medical services which were provided by Plaintiff's assignor 6. The prices charged by Plaintiff's assignor were the prices that Defendant, LARRY R SHELLER, agreed to pay. 7. Plaintiff avers that there is a balance due and owing from Defendant, LARRY R SHELLER, in the amount of $ 6,160.08 as of APRIL 10 2009. 8. Plaintiff claims interest at the legal rate of six (6%) percent per annum from APRIL 10 2009. 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the aforementioned balance, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, LARRY E SHELLER, in the amount of $ 6,160.08 with continuing interest thereon at the rate of 6% per annum from APRIL 10 2009 and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. JAMES C W BRC PA I.D. #4 WELT EINBE 1400 Ko er Building 436 Sev nt Avenue Pittsb A 15219 (412) -7955 , Esquire & REIS CO., L.P.A. W WR#:6609734 11/25/08 PAGE 001 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MEDICAL CTR AS OF 11/24/08 361 ALEXANDER SPRING RD CARLISLE PA 17015 PHONE (717) 960-1680 ---- ------- ------------------------------------------------------------------ PATIENT: SHELLER, LARRY R F/C: P P/T: 0 A/C: 9349842 DSC CODE: 01 TO: SHELLER, LARRY R ADMISSION: 09/21/06 DISCHARGE: 09/21/06 1048 TRINDLE ROAD CARLISLE PA 17013 D E P A R'T M E N T A M O U N T 79.97 308.75 142.29 2,096.66 176.66 140.00 721.23 2,494.52 6,160.08- ----------------- --------------------------------------------- TOTAL 0.00 SELECT: REV= * DEPT= * CHGCD= * DATE/MDCY= * TO/MDCY= CMD:I=DAR,2=PAT 4=DETAIL 7=RETURN,8=BACKWARD, ENTER=FORWARD VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn falsifications to authorities, that she is GAIL WOOD (Name) DIRECTOR OF CUSTOMER CARE of INTERNATIONAL PORTFOLIO INC., plaintiff (Title) (Company) herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of her knowledge, information and belief. (Signature) WWR# 0 FIND- &-FKDE 2 0 0 9 APR 20 Phi 3: 23 "X51 418.50 flD Arty alcr 88(0 8,-1o y P-T* ?&3191 Sheriffs Office of Cumberland County R Thomas Kline„ tr of L 1t+pb'.t4 Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy FCF . ,G Th` SKERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/22/2009 03:07 PM - Jason Vioral, Corporal, who being duly sworn according to law, states that on April 22, 2009 at 1507 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Larry R. Sheller, by making known unto himself personally, defendant at 1048 Trindle Road Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $32.50 April 23, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 2009-2488 International Portfolio Inc. VS Larry R. Sheller By Corporal r? ? ?n WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2488 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due INTERNATIONAL PORTFOLIO INC. Plaintiff (s) From LARRY R. SHELLER, 1048 TRINDLE ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS FIRST FCU, 1711 SPRING ROAD, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6,273.49 Interest $987.94 Atty's Comm % Atty Paid $156.50 Plaintiff Paid Date: APRIL 16, 2012 (Seal) L. L.$.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff VS. LARRY R SHELLER Defendant(s) Civil Action No. 09-2488 CIVIL TERM YA Ow- <<5ic, yA ?? t:? MEMBERS FIRST FCU J ? ( ( Garnishee(s) TO THE PROTHONOTARY: .4 j Ct??lQ-1 "1arS PRAECIPE FOR WRIT OF EXECUTION - -{ CD -n CD'-r; -Fr CD p, X Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against LARRY R SHELLER , Defendant 3. against MEMBERS FIRST FCU,, , Garnishee 4. Judgment Amount $ Less Payments/credits received $ Interest $ Costs $ SUBTOTAL: $ Costs (to be added by Prothonotary): $ cz? s° $6,273.49 $0.00 $987.94 $7,261.43 WELTMAN, WEINBERG & REIS CO., L.P.A. By: (?? n?-=? William T. Molczan, squire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. Q ^ 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 -7 6 Sd p u (412) 434-7955 )L/ Do ,, ?. S a ?1'SL • 5o P? G aas? "p a4` C Lt4 i bC1&&1 Q WWR No. 6609734 -l-- & ? ? -7 3d' w r ? -T uea IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION INTERNATIONAL PORTFOLIO INC Plaintiff vs. LARRY R SHELLER Defendant(s) MEMBERS FIRST FCU Garnishee(s) No. 09-2488 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6609734 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 6609734 INTERNATIONAL PORTFOLIO INC VS. LARRY R SHELLER, and MEMB1 RS I ST FCU Garnishee(s) Attorney for Plaintiff(s) :: ?=-' - ,- - T' C-) = w - CUMBERLAND County Court of Common Pleas NO. 09-2488 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), MEMBERS 1 ST FCU, , only. WELTMAN, WEINBERG & REIS CO., L.P.A. By t?? I William T. M zan, Esquire Attorney for Plaintiff % R'" a C?µ J0g4)49gR l2o a- Ny 14/ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 'V' t 01 2012 NOV -8 AM 9: 10 IU?ENNSYLVgNCOUN-f IA p: International Portfolio Inc. vs. Larry R. Sheller Case Number 2009-2488 SHERIFF'S RETURN OF SERVICE 04/20/2012 09:30 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 20, 2012 at 0931 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Larry R. Sheller, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Meg Beaston, Member Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on April 23, 2012 to Larry R. Sheller at 1048 Trindle Road, Carlisle, PA 17013. 11/07/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.92 SO ANSWERS, November 07, 2012 RON R ANDERSON, SHERIFF , sa aPd, SHERIFF'S OFFICE OF CUMBERLAND COUNTY